All University policies and procedures are located in one central on-line location in the University Policies and Procedures Library maintained by the University Compliance Office at http://policies.fiu.edu/. All of the policies and procedures of the Office of Research and Economic Development may be reviewed on that database which is arranged by Pre-Award and Award, Post-Award, Office of Research Integrity and Office of Technology Management and Commercialization. Additionally, users may search the database using key words and all policies and procedures containing the key words will be listed, regardless of the University unit to which they pertain. This is particularly useful for sponsored research matters as administration of projects routinely involves other University units such as Purchasing, Travel, Risk Management and Environmental Health and Safety and many other units. Thus, the ability to search the Policies and Procedures Library using key words provides users with an expedient way to ensure that all relevant policies and procedures are accessed. The on-line policies and procedures also list the appropriate University contacts so that users may know whom they can call if they have any questions on the policies or procedures. Needed forms and background information are also included in the policies and procedures.

3. I need a confidentiality agreement, teaming agreement, material transfer agreement or memorandum of understanding executed on behalf of the University. Can I process that through the Office of Research and Economic Development, and if so, how?

Pre-Award may execute agreements that are not related to an existing proposal or sponsored project, but which are related to research or to potential future sponsored research projects or related to University intellectual property as follows.
Examples of these types of agreements are:

Memoranda of Understanding setting forth that the parties will work together to determine if a research project may be pursued in the future;

A draft of the proposed agreement, if the PI has a draft (e.g., the form FIU confidentiality agreement with the blanks filled in)

Pre-Award will determine if the agreement is appropriate for execution by Pre-Award and if needed, will negotiate the agreement with the entity with which the agreement will be executed. The negotiation will be done in consultation with the PI and other FIU units, as necessary (e.g., Office of the General Counsel, Office of Technology Management and Commercialization). When the agreement is signed by all parties, Pre-Award will send a copy to the PI.

Special Considerations relating to Material Transfer Agreements

If a Material Transfer Agreement (MTA) seeks to transfer any Special Hazards Material (as defined in policy #125.405, Security in Laboratories with Special Hazards), the PI must obtain the approval from Environmental Health & Safety (EH&S) before the MTA may be signed by Pre-Award. Policy #125.405 defines Special Hazards Materials as including, but being not limited to, radioactive materials, Drug Enforcement Administration (DEA) controlled substances, select agents, carcinogenic and explosive materials, infectious materials, and laser devices, and any other hazardous materials, the purchase, handling, storage or transfer and disposal of which is regulated by federal, state, or local laws.

The PI must provide to Pre-Award, the appropriate EH&S Research Clearance Form (found on the Pre-Award website at http://www2.fiu.edu/~ehs/dsrt/index.htm) with EH&S approval of the transfer of the materials.

If the MTA is for the transfer of animals, the PI must work with the Laboratory Animal Research to ensure the Facility is prepared for the transfer and the care of the animals. Any IRB, IBC or IACUC approvals must also be in place, as applicable, before beginning to use the material transferred in any research project. See Office of Research and Economic Development Policy #2350.060, Purchase or Receipt of Items Requiring EH&S Prior Approval.

4. Who may sign award documents on behalf of the University for sponsored projects?

All negotiations of sponsored project awards and agreements must be accomplished by a representative of Pre-Award. FACULTY AND STAFF MAY NOT EXECUTE SPONSORED PROJECT AWARDS OR AGREEMENTS ON BEHALF OF THE UNIVERSITY. Faculty and staff are not official signatories for the University on sponsored project documentation and therefore, may not execute such documentation.

FDP stands for Federal Demonstration Partnership. Awards under FDP allow the University to administer certain matters relating to federal grants without prior approval from the sponsor. Your award document from the sponsor will state if the grant is issued pursuant to the FDP.

6. I have not received approval from IRB/IACUC/IBC but my grant is ready to be funded. What should I do?

FIU and most funding agencies will not release funding for spending until IRB/IACUC approval has been verified. Contact Pre-Award and/or the IRB/IACUC/IBC Coordinator for assistance. Also, subsequent funding years will not be released if the IRB/IACUC/IBC is not in compliance and active (i.e. annually submitted for review and approved).

8. My grant calls for a subcontract to be prepared. How do I go about it?

See ORED policy #2350.090 – Subaward Preparation and Payment to Subrecipients on Sponsored Projects found on the University Policies and Procedures Library at: http://policies.fiu.edu/files/367.pdf

9. I am hiring another FIU department to do work on a grant? How do I go about it?

Service / Recharge centers are departments within the University that charge a fee for the services they perform. Some of the costs associated with these centers are recovered by charging the sponsored project a pre-approved service fee. An example of a recharge/service center is the Duplicating Services Department.

Purchases from Service/Recharge Centers are done by interdepartmental transfers for the services performed by the recharge center.

10. How are graduate tuition waivers processed?

See ORED policy#2350.080 – Stipend and Other Payments to Students and Temporary Personnel on Sponsored Projects found on the University Policies and Procedures Library at: http://policies.fiu.edu/files/361.pdf

Graduate student support must be included in proposals in which the funding agency and the project permit graduate student support. Unfortunately, this practice has not always been followed, and more importantly, in many instances in which the student support was available in budgets of funded grants, some Colleges have utilized tuition waivers from the University Graduate School instead of supporting students through the grants. This costly and inappropriate practice must not continue. The Office of Research and Economic Development will review grant proposals for adherence to this directive. Training and support of graduate students in our funded research is an integral element in reaching the University’s goal of achieving the next level of scholarly excellence.

11. Must I use a U.S. Air Carrier for my sponsored project?

Air Travel on federally sponsored projects must use U.S. flag carriers to the maximum extent possible when commercial air transportation is used between the United States and a foreign country or between foreign countries. Cost savings, convenience or personal preference, are not exceptions to using non U.S. flag air carrier. For more information on exceptions, see the website at http://www.fic.nih.gov/funding/grants_info/travel.htm.

12. Where can I find information on the balance of my accounts/status of payments?

If a budget modification is needed, the PI requests the budget modification by filling out the Budget Modification Request Form found in the forms section of the Office of Research and Economic Development website. The Budget Modification Request Form must be completely filled out and forwarded via email to the ORED Post-Award representative for the particular Project ID. If a College and Center Administrator is submitting the Budget Modification Request on behalf of the PI, then the PI must be copied on the email request. The ORED Post-Award representative will review the request and the sponsor’s award document and guidelines, as well as the FIU policies and procedures to determine if the modification may be made. If the modification is appropriate, a ORED Post-Award representative will process the budget modification request directly in PantherSoft.

If ORED determines that a budget modification cannot be made without the sponsor’s prior approval, ORED will notify the person requesting the budget modification that the sponsor must be contacted. The PI must send to the ORED Post-Award representative the details of why the budget modification is needed. The PI may do this by sending the ORED Post-Award representative either (1) an email with the details or (2) a draft letter addressed to the sponsor with the details. The ORED, Post-Award representative will review the details as to why the budget modification is needed and will then either email or send the letter to the sponsor contracting officer to request approval for the budget modification. The ORED Post-Award representative will copy the PI on that correspondence. If the sponsor contracting officer approves the budget modification in writing via letter or email, ORED Post-Award representative will process the same. Requests for budget modifications to the equipment category or other budget categories towards the end of a project period will normally not be allowed without sponsor written approval.

All budget modifications that affect F&A on the project must be approved in writing by the PI’s Dean and the Associate Vice President for Research before any budget modification is processed by ORED, Post-Award representative.

F&A is lost when money is transferred from a category which can be assessed overhead to a category which cannot. In order to calculate the loss of F&A, multiply the dollar amount that you are transferring from the overhead-bearing category to the non-overhead-bearing category by the indirect cost rate of your grant.

16. What is a No Cost Extension (NCE)? What do I need to do?

A No Cost Extension (NCE) extends the ending date of a grant award without adding any additional funds.

18. My research project involves payments to human subject participants. How do I go about paying them?

Payments to human subject participants, whether in cash or with gift cards, may only be made if such payments were: (1) approved, in writing, by the IRB, and (2) approved by Post-Award verifying that the budget for the Project ID includes funding for the payments to be made.

STEP ONE

The first step in the process for approval of cash or gift card payments to human subjects is for the PI to complete the applicable Office of Research and Economic Development form and provide it to Post-Award. All forms are on the Office of Research and Economic Development website:

For participants who will be paid in cash or by check, use the Advance for Research Subject Payments form.

For participants who will be paid with gift cards, use the Gift Card Request for Research Subjects form.

For participants who are FIU employees, use the Research Subject Payment form.

Provide the completed applicable form to the Post-Award representative for your Project ID. The request will be reviewed to ensure IRB approval for the payments and availability of funds in the project budget. If approved, the form will be signed and the PI will be provided a budget.

STEP TWO

The PI may then proceed to request that the payment to the participants be made as set forth below.

Note that the PI must keep a copy of the documentation regarding the participants’ payment for the length of time applicable to the Project ID as specified in Office of Research and Economic Development policy #2350.065, Records Retention Schedule for Sponsored Project Documents, for production to the project sponsor, the FIU IRB or any agency having oversight authority over the conduct of human subject research or in case of audit. Such production shall be done in accordance with the confidentiality requirements of the research study, if any. Documentation related to human subject participant payments are subject to review at any time by the Office of the Controller, Internal Audit or the Office of Research and Economic Development.

Cash Payments to Participants
Cash payments for human subject participants may be processed using a Participant Payment Cash Fund via the Controller’s Office. A Participant Payment Cash Fund is intended to provide cash to a department or project PI, or designee, for the sole purpose of easily making small payments to participants of research projects. The procedures related to requesting and reconciling the Participant Payment Cash Fund are found on the Controller’s website at http://finance.fiu.edu/controller/QL_ControllerProceed.html under the ‘Participant Payment Forms and Procedures’ section.

Check Payments to Participants
For payments to be made to participants via check, the payment must be processed through the FIU vendor payment system (Accounts Payable). The PI must submit an Unencumbered Payment form to Accounts Payable. The Procedures related to that form are found in the ‘Accounts Payable’ section of the Controller’s website at http://finance.fiu.edu/controller/QL_ControllerProceed.html.

Payments to Participants via the FIU Payroll System
Payments to human subject participants who are employees of FIU must be made via the FIU payroll system, so that the withholding required by the IRS may be met. Once the Research Subject Payment form, located in the Office of Research and Economic Development web site, has been approved as described above, Post-Award will forward the signed form to the Human Resources, Payroll Department, for processing of the payment to the employee via the payroll system.

19. How do I determine if I need to do a subcontract or consulting agreement versus a vendor agreement (procurement action through purchasing) for an entity in my awarded project?

Depending on what purchase is being made, you will need a subcontract, a consulting agreement or a contractor (a/k/a vendor) agreement. Speak to your ORED, Pre-Award, representative about which document is needed for your situation

Subcontracts or Consulting Agreement vs. Contractor (a/k/a Vendor) Agreement?
The distinctions between subcontracts/consulting agreements and contractor agreements are generally guided by the federal regulations, sponsor regulations and State of Florida statutes. Please see the Checklist to Determine Subrecipient or Contractor Involvement at http://research.fiu.edu/forms/index.html to determine whether a subaward or contractor agreement is appropriate for your situation.

A contractor agreement generally is used when FIU buys goods or services from a contractor in the general and usual course of the contractor’s commercial business. Examples of such procurements are the purchase of non-specialized equipment, supplies, printing services and other products and services generally provided in commercial activities. In these instances, the activity is a procurement, and the entity receiving the funds is a contractor. A subcontract is generally not required for these procurements; rather the procurements are done via a purchase order obtained through a Panthersoft requisition or by way of a Pro Card purchase.

The subcontract or consulting agreement process is used when FIU passes-through a portion of the sponsored award to another entity (in the case of subcontracts) or person (in the case of consulting agreements) for the purpose of programmatic effort on the project. Rather than a general commercial purchase, the subrecipient will be responsible for managing the technical and administrative aspects of its part of the overall sponsored project in accordance with the scope of work detailed in the subaward. All the terms and conditions that are part of the primary award from the project sponsor that are applicable to the sub-recipient must be included in the sub-award document and flowed down to the subrecipient. Accordingly, a written subcontract or consulting agreement is required for these programmatic purchases and signature of acceptance of these terms by the receiving entity/person is required. The entity or person receiving the funds is a subrecipient.

If you need additional guidance when preparing your proposal budgets as to whether your proposed item is a subaward as opposed to a procurement of goods or services processed through the Purchasing Office then please contact your Pre-Award Representative at 305-348-2494.

20. When can I purchase a computer with federal grant and contract funds on my sponsored project?

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